Technical and Regulatory Guidance for In Situ Chemical ... - ITRC

ITRC – Technical and Regulatory Guidance for In Situ Chemical June 2001
Oxidation of Contaminated Soil and Groundwater
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Drilling of monitoring wells for performance monitoring. Again, at least part of this cost is
usually associated with the RI.
T he oxidant chemical itself. Equations for calculating the amount and cost of each type of
oxidant based on site-specific conditions are included in Appendix D.
Laboratory analysis of water and/or soil samples to establish a baseline and evaluate the
performance of the oxidant.
Contractor costs for labor, mobilization and demobilization, injection of the oxidants, and
collection of confirmation samples.
Infrastructure necessary to implement ISCO, including utilities, fencing, improvements
necessary for site access, etc.
Permits and/or regulatory oversight required for the project.
Some cost estimates from actual ISCO implementations are available in Appendix B, “Case
Studies.” Relative cost comparisons of ISCO and other innovative in situ technologies are presented
in the ITRC document “Dense Non-Aqueous Phase Liquids (DNAPLs): Review of Emerging
Characterization and Remediation Technologies.”
7.0 TRIBAL AND STAKEHOLDER CONCERNS
Stakeholders and representatives of any affected tribes should be involved at every stage of the
evaluation, selection, and permitting of treatment systems and in the selection and performance
evaluation of vendors. Such involvement will lead to better, more defensible solutions and will
expedite the cleanup of contaminated sites. One of the objectives of the responsible parties must be
to integrate tribes and stakeholders into all of their processes.
Since chemical oxidation methods are a relatively new technology, when such technology is being
considered for permitting or deployment for the first time in a given area, stakeholders and tribal
representatives should be given the opportunity to comment on it and to make their issues, needs,
and concerns known. Information about the technology, including alternatives analysis, should be
made widely available for public comment.
Chemical oxidation methods may have the potential benefit of cleaning up a contamination problem
quickly and therefore may be regarded favorably by tribes and stakeholders. However, since
chemical oxidation methods involve the introduction of a chemical reagent into the environment,
tribes and stakeholders will have the obvious question “Will it do any harm” This question must
be addressed carefully and honestly.
In some instances, one can cite the examples where the technology has been tried before and report
on its success or failure in each situation. In the case of an immature technology, one may be in a
situation where one is proposing a solution that is believed to be likely to work but has not been tried
previously in a parallel situation. In this type of case, one must give accurate and honest information.
Explain all of the reasons why you believe that the technology is likely to work. Give the details of
what you believe to be the possible failure scenarios. How likely is the technology to fail What
damage might be done Have public discussion about the alternatives. It is possible that tribes and
stakeholders will embrace an opportunity to try a new solution to a contamination problem,
particularly if there is a good chance that it may succeed where other solutions are likely to fail. Be
open about the potential risks and benefits. The affected tribes and stakeholders must be given the
opportunity to weigh the potential risks against the potential benefits, since they are often the ones
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